The Supreme Court held that a conviction under Sec. 7206 for willfully filing a false tax return (or for aiding and abetting filing a false tax return) is an aggravated felony that can result in deportation.
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International Tax
FinCEN Once Again Extends FBAR Filing Deadline for Certain Financial Professionals
FinCEN announced a further extension of the deadline for filing FBARs, to June 30, 2013, for a small group of financial professionals
Foreign Tax Credit Regs. on Splitter Arrangements, Determining Who Is Liable for Foreign Tax
The IRS issued final regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit purposes and temporary regulations on the application of the “anti-splitter” rules of Sec. 909.
Proposed FATCA Regs. Take Comprehensive Approach
The IRS issued proposed regulations providing rules on information reporting by foreign financial institutions (FFIs) and withholding on certain payments to FFIs and other foreign entities.
Specified Foreign Financial Assets Reporting Regs. Issued
The IRS issued temporary and proposed regulations on the requirement that certain foreign financial assets be reported to the IRS for tax years beginning after March 18, 2010.
The Dual Consolidated Loss Quandary
The rules and regulations pertaining to dual consolidated losses are very complex; practitioners should always be diligent and aware of possible DCL scenarios.
Statutory Definition of Specified Notional Principal Contract Extended Through 2012
The IRS issued temporary and proposed regulations on dividend equivalents for purposes of Sec. 871(m).
IRS Announces Third Offshore Voluntary Disclosure Program
The IRS announced it is starting its third program designed to help people hiding offshore accounts get current with their taxes in the United States.
New Reporting for Specified Foreign Financial Assets
Effective for tax years starting after March 18, 2010, new Sec. 6038D requires individual taxpayers to report any interest in “specified foreign financial assets” if the value of these assets in aggregate exceeds an applicable threshold amount.
Foreign Financial Asset Reporting Form Finalized
The IRS released the final version of Form 8938, Statement of Specified Foreign Financial Assets, and its instructions.
Regulations Issued for Specified Foreign Financial Assets Reporting
The IRS issued temporary and proposed regulations on the requirement that certain foreign financial assets be reported to the IRS for tax years beginning after March 18, 2010.
IRS Reminds Dual Citizens and Americans Living Abroad of FBAR, Other Filing Requirements
In a fact sheet, the IRS reminded U.S. citizens and dual citizens of the United States and foreign countries who live abroad about U.S. filing requirements.
Unreported Offshore Accounts: A Hidden Danger for Clients
Criminal penalties for not reporting offshore accounts can be harsh. This item provides action steps for CPAs.
Passive Foreign Investment Companies
This item assesses various planning alternatives that may help U.S. taxpayers avoid the negative aspects of the PFIC regime, including qualifying electing funds, mark-to-market elections, and various planning strategy options.
Are Hedge Funds and Private Equity Funds Foreign Financial Accounts?
This item discusses whether investments in or management of hedge funds and private equity funds should be included within the scope of the FBAR filing requirements.
Final Regs. Issued on Killer B Transactions
The IRS has issued final regulations to close a loophole (known as Killer B transactions) that allowed one or more foreign corporations involved in a triangular reorganization to repatriate earnings tax free to the United States in certain circumstances.
Tax Court Determines Character, Source of Golfer’s Worldwide Endorsement Income
The Tax Court recently decided Goosen, a case with potentially far-reaching implications for foreign athletes who perform within the United States. The decision has become the leading authority for determining both the character and the source of the endorsement income earned by international athletes.
IRS Will Phase in Implementation of FATCA Requirements
The IRS announced plans to phase in the requirements of the Foreign Account Tax Compliance Act (FATCA) because of numerous comments it has received about the difficulty of implementing the requirements.
Final Regs. Issued on Determining Amount of Tax Paid for Foreign Tax Credit Purposes
Final regulations have been issued that provide guidance on determining the amount of taxes paid for purposes of determining the foreign tax credit.
IRS Clarifies September 9 Extension for Offshore Reporting
The IRS clarified that its postponement of deadlines under the 2011 OVDI also applies to taxpayers filing FBARs and other information returns pursuant to FAQs 17 and 18.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
